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Background

Background. WHIP, EQIP, and CSP contracts require “AGI Eligibility Determinations” using the Farm Service Agency subsidiary eligibility web service. In ProTracts, beginning in FY2007, a second digit was needed to distinguish these new contracts from 1997 contracts.

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Background

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  1. Background • WHIP, EQIP, and CSP contracts require “AGI Eligibility Determinations” using the Farm Service Agency subsidiary eligibility web service. • In ProTracts, beginning in FY2007, a second digit was needed to distinguish these new contracts from 1997 contracts. • On new 2007 applications or contracts created in ProTracts between October 10 and November 2, 2006 for CSP and EQIP, the AGI determination value was set to “Pre 2003 AGI not Required” and erroneously exempted from the AGI provisions.

  2. AGI values are determined at the time a contract is obligated and, unlike other eligibility flags, is not updated annually. • ITC has scripted and removed all the incorrectly labeled values of “Pre-2003 AGI Not Required” for 2007 application/contract and reset to the current AGI value; the majority were set to “Yes”. • A spreadsheet provided by email on 3/13/07 listed the records that remained “No” for applications and contracts, with tabs for both summary and details (including contract number). • The applications where AGI equals “No” cannot be approved until AGI issues are resolved.

  3. Actions: By June 1, 2007 • Identify contracts that have AGI values of No or “not filed” from the spreadsheet. • Access applications or contracts in ProTracts and use “Update Eligibility” to apply eligibility rules against the latest AGI or AD-1026 web service value. • The AGI values have been reset in Fund Manager but applying eligibility rules are “user actions” that must take place locally. Users must use “Update Eligibility” to have the eligibility rules implemented against the current value.

  4. Before Update AfterUpdate

  5. Actions • Where AGI is No due to “not filed” notify participants of need to file within 30 days of receipt of notification letter (Attachment B). • Applicants that are “not met” may require confirmation with FSA. • If applicant or participant does not file AGI or does not meet AGI within 30 days, notify applicant or participant of their ineligibility for the program using existing ProTracts sample ineligibility letter for applications and Attachment C for contracts. • No payments should be processed for participants that have not filed AGI. There is no ProTracts block on payments for AGI since this should have been blocked during application .

  6. Fund Committal Date Reminder Some eligibility issues take 7-14 days to resolve through the eligibility web services so plan accordingly to meet NRCS April 30, 2007 fund committal deadline.

  7. Key NRCS References • 440 CPM Section 512.22 - Eligibility • 440 CPM Section 512.98 - Program Eligibility Matrices for Individuals, Entities, and Joint Operations 440 CPM 515 Subpart F - Program Eligibility • NRCS-CPA-1202-CPC (Appendix) • NB 440-7-1 • National Food Security Act Manual

  8. Eligibility Matrix in 512.98 AMA CSP EQIP WHIP

  9. ProTracts/Fund Manager Eligibility Checks Specific Block for AD-1026 to be added in October 2007 in addition to HEL/WC

  10. Key FSA References • Notices PL-137, PL-146, PL-147 • Notice CM-518 • Notice CP-589 • 1-CM 750-754 Note: some are expired notices and are for reference only.

  11. 1-CM 753 FSA Subsidiary Responsibilities: Web-Based Eligibility System • For the administration of all programs, FSA’s primary responsibility with regard to the web-based eligibility system is to ensure that the files are updated accurately and timely. • Specifically for the administration of EQIP, this provision applies to accepting and recording determination information for each of the following: • • AGI certifications, either filed by the producer using CCC-526 or other acceptable certification according to 1-PL • • AD-1026 certification. • Note: If the producer is not associated with land, the producer is still required to complete AD-1026 certifying compliance with HELC/WC provisions.

  12. NRCS/FSA Web Services FSA AGI web service is used by NRCS to read: • Permitted entity file on the Kansas City mainframe to determine member information for joint operations and entities. • A subset of these values is then used in the NRCS EQIP Payment Limitations determination. • Data is used to attribute payments to “warm body” level for 1614. FSA subsidiary web service provides information to determine : • Status of compliance with AD-1026, HELC and WC, according to 6-CP as of the date accessed • AGI eligibility using member information from AGI web service.

  13. Applicant Certifications CPM Part 404 512.20 Subpart C – Application for Assistance Certifications Required (1) Before NRCS can proceed further, the applicant must be established in the Service Center Information System (SCIMS) and have the following certifications completed and filed at the USDA Service Center: (i) Form AD-1026—Highly Erodible Land Conservation and Wetland Conservation (HELC/WC) Certification. (ii) Form CCC-526—Adjusted Gross Income (AGI) Certification. • Form CCC-501A—Member’s Information (for entity and joint operations only). See form instructions. (iv) Signature authority of an individual requesting benefits for an entity or joint operation. (See section 512.21.)

  14. AGI Determination from CCC-526 • AGI is determined in the year of the contract and determined prior to contract obligation. Where “Yes”, remains in effect for the life of the contract. • Exception: if the AGI eligibility changes from “No” for an entity member to “Yes” in later years it will be updated.

  15. AGI Determination • AGI eligibility of the participant is not affected by the eligibility of the members. • Exceptions are General Partnerships and Joint Ventures, where the participant does not have eligibility itself but derives it's eligibility from it's members. • Exception during a contract modification if a new participant is added to the contract, or a participant's member share is increased, then eligibility is re-determined due to the participant change.

  16. AGI Determination • AGI eligibility of the members will affect the calculation of EQIP payment limitations. The payment limitation of the participants is decreased by the ownership share of any members who are AGI ineligible. • Some business types require ownership shares (see 512.98), and there will be an AGI eligibility failure if no owners are found, or if the ownership shares do not add to 100%.

  17. EQIP Payment Limitations • FSA AGI web service provides ownership shares for the business types. • If there are missing or incomplete values for the members, the payment limitation eligibility is set to “No”. • The subsidiary web service then is run, and for each business type which requires members, each member is reviewed to determine their individual eligibility.

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